Colour-coded waste disposal explained

The new HTM attempts to provide clear direction to healthcare waste producers and offers advice on a wide range of key healthcare waste related issues including waste segregation, documentation, transport, training and auditing.

The document has received a mixed reception in the NHS and the private sector. One of the key areas of both concern and interest has been the new colour coding guidance. Many healthcare professionals have expressed concern regarding the use of the colour yellow for incineration only wastes and orange for those wastes suitable for alternative treatment (AT). The question has been asked why this was not the other way round as the bulk of the waste produced by the NHS in England and Wales is now required to be disposed of in orange bags. This topic could be debated indefinitely and no doubt will, but the document has been published and the colour coding is clear. A summary of the colour coding system is provided in Table 1.

The Environment Agency and Department of Health are recommending that all existing healthcare organisations adopt the new colour coding by the end of this year, within one year of the HTM being published. Some Trusts have defiantly stated that they will not be implementing orange bags, particularly those who currently have incineration only contracts. Is this decision a wise one? It is possible to see their point of view, but have these Trusts considered future tendering exercises where considerable cost savings could be made through the segregation of waste suitable for AT? Also, are they confident that their ontractor’s contingency plans do not include AT disposal – if they have contingency plans at all?

Understanding your waste

The management of waste in healthcare facilities is now more complex than ever before, and requires Trusts to review, and in many cases change, their existing systems and practices.

The new colour coding system cannot be introduced without a degree of planning as well as understanding the content of waste streams and of course, considerable staff training. Areas producing incineration only wastes need to be identified and this might not only be those obvious areas such as labs, maternity, theatres, etc.

For instance at ward level are partially used IV bags (which may contain pharmaceutical residues) currently disposed of into yellow bags? If this is the case and the Trust is seeking to introduce orange bags, how would this waste be segregated, contained and identified to ensure it is disposed of via incineration? Even those wastes which are obviously anatomical, such as biopsies and samples from laboratory areas, might not be straightforward. They are anatomical wastes and require incineration, but they may also have been preserved in chemicals such as formalin, which needs to be considered when providing an accurate waste description on the waste consignment note.

Managing the change

So, what do the changes really mean for the waste producers? In summary they include:

A major driver for these changes is the very real fear that waste from the healthcare sector is being disposed of incorrectly. The Environment Agency (EA) has voiced its concerns, and believes that the introduction of the new colour coding scheme will standardise practice and help prevent wastes requiring incineration only from being disposed of via alternative treatment plants.

In 2006, the EA indicated that some incineration only wastes had found their way into alternative treatment processes, including anatomical and pharmaceutical wastes. This finding was stated as being one of the main reasons for the EA’s recent targeting of the healthcare sector, for in-depth and detailed audits and inspections.

The requirement to change waste management practice and to fully comply with the Hazardous Waste Regulations 2005, is significant, and does place a considerable burden, on invariably, an already stretched facilities or estates management teams. The new changes can be led and driven by these departments. However it has to be acknowledged that the management of wastes is everyone’s responsibility.

Often the changes detailed in the guidance are perceived as negative. This viewpoint, however, does not recognise the potential opportunities that the new legislation and particularly new waste descriptions present. NHS Trusts and other producers have continually struggled to adequately segregate their “domestic” wastes from their “clinical” and continue to pay huge premiums for the privilege. The clinical waste disposal companies recognise this and continue to “dine out” on the producer’s inability to put waste in the correct container.

Significant investment in the clinical waste disposal sector over recent years suggests that contractors are not expecting healthcare waste producers to be too successful in minimising their most expensive waste types. The reality is that significant operational and economic benefits can be achieved by implementing structured segregation schemes. Placing non-clinical/hazardous wastes in the correct bag is achievable and there are very few estates or facilities departments who could not utilise the savings. With estimates of 40-60% of clinical/hazardous waste being in fact domestic or potentially recyclable waste there are potential savings to be made by using the colour-coded sacks.

All too frequently waste producers rely on their waste contractors to decide what is in their waste and in many cases complete a majority of the legal paperwork (hazardous waste consignment notes) for them. This is completely inappropriate as the Trust, not the contractor, is the producer of that waste and therefore it is the Trust which has the responsibility to provide an accurate description of the waste.

Pre-acceptance criteria audits

The requirement for producers to fully understand their wastes and their waste production activities increases further with the introduction of ‘Pre-Acceptance Criteria’ (under the Sector Guidance Note IPPCs5.06 – Guidance for the Recovery and Disposal of Hazardous and Non- Hazardous Waste – Appendix 6: PPC for Clinical Waste 2007). Waste disposal companies will be required, as part of their permit conditions, to obtain specific information in writing, from the producer of the waste (i.e. Trusts/hospitals), in relation to: